NASPO Anti-trust Statement

NASPO INTERNATIONAL Antitrust Policy

NASPO intends to comply with all applicable antitrust laws. Under no circumstances will NASPO directly or indirectly be involved in conduct that leads to or implies an agreement among its members that would restraintrade and/or otherwise violate antitrust laws. Any conduct by NASPO’s officers, directors, or contractors that is contrary to the antitrust laws is contrary to NASPO policy. Any officer, director, or employee found in violation of thispolicy or the applicable antitrust laws will be subject to appropriate disciplinary action.

Guidelines for Antitrust Compliance

A meeting shall be held only if there are proper matters to be discussed which justify the meeting.

For each meeting an agenda should be developed and provided to each attendee.

The agenda should be specific and avoid topics that may cause antitrust problems such as price, production, markets, and selection of customers or suppliers. In addition, discussions of price, pricing, discounts, credit terms, refusals to deal and allocation of markets should be avoided.

Participants at meetings should adhere strictly to the agenda. In general, subjects not included on the agenda should not be considered at the meeting.

If a subject of doubtful legality is brought up at a meeting, the person leading the discussion should be told immediately that the subject is not a proper one for discussion and discussion should be halted. Should the discussion continue, despite protest, it is advisable that attendees leave the meeting.

Minutes of all meetings should be kept that accurately report what actions, if any, were taken.

Unscheduled, informal, secret, or “rump” meetings held in conjunction with the regular meeting should be avoided. Such meetings seriously jeopardize legitimate Council activities and create a very substantial risk of investigation. An association member should attend all meetings.

No meetings should include recommendations with respect to “sensitive” antitrust subjects, such as those listed in #3 above.

Members should not be coerced to take part in association activities.

Make certain that no officer, director or member of the organization makes any statement – orally or in writing-which states or appears to state an official policy or position of the organization without specific authorization of the organization to do so.

Legal counsel should attend all organization meetings where there is potential to discuss legally sensitive subjects.

Members should check with organization staff and/or counsel if there is any doubt about the propriety of an organization program or subject of discussion. Members may also wish to consult with their company’s counsel.

Members should cooperate with the organization counsel in all matters, particularlywhen counsel has ruled adversely about a particular activity